EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for...more
Large quantity generators (LQGs) of hazardous waste who accumulate hazardous waste for no more than 90 days know proper adherence to unit-specific and facility-wide closure requirements is an essential condition for exemption...more
Arguably, the Social Cost of Carbon (SCC) is one of our society’s most important numbers. The SCC is used in all climate decisions and will now be considered in all significant governmental decisions and federal actions. How...more
3/15/2021
/ Biden Administration ,
Carbon Emissions ,
Chesapeake Bay ,
Clean Water Act ,
Climate Change ,
Coastal Real Estate ,
Department of Justice (DOJ) ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Waste ,
New Guidance ,
Obama Administration ,
Regulatory Agenda ,
US Army Corps of Engineers
Generators of hazardous waste have long understood the importance of emergency preparedness and prevention to regulatory compliance and facility safety. Contingency planning and coordination with emergency service providers...more
Some companies subjected to environmental enforcement or cleanup actions may believe others should take the blame or share in the costs. When environmental consultants have been involved, the finger can point in their...more
10/31/2019
/ CERCLA ,
Coal ,
Coal Ash ,
Coal Industry ,
Consultants ,
Enforcement ,
Environmental Liability ,
Environmental Protection Agency (EPA) ,
Federalism ,
Hazardous Waste ,
Proposed Rules ,
Section 401 ,
Stormwater Discharge Permits
In 2016, EPA published the long-anticipated Hazardous Waste Generator Improvement Rule (HWGIR) updating requirements for generators of hazardous waste. The HWGIR also clarifies EPA polices governing accumulation of hazardous...more
Certain pharmaceuticals are regulated under the Resource Conservation and Recovery Act (RCRA) as “hazardous waste” when they are discarded. EPA recently finalized new management standards for hazardous waste pharmaceuticals...more
EPA has announced a new compliance policy that some will view as providing welcome relief to industry and others may view as providing unwarranted concessions. The subject line of the EPA memo announcing the new policy is...more
10/3/2018
/ Adjacent Property Owners ,
Clean Air Act ,
Clean Water Act ,
Clean Water Rule ,
Coal ,
Coal Ash ,
Discharge of Pollutants ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Waste ,
New Guidance ,
RCRA ,
Sierra Club ,
Strategic Enforcement Plan ,
Toxic Substances Control Act (TSCA) ,
Waters of the United States
The Clean Power Plan (“CPP”), and its companion new source review rule, is the Obama Administration’s signature regulation on reducing greenhouse gas emissions from power plants. Among other things, it requires states to put...more
5/17/2017
/ Agricultural Sector ,
Clean Power Plan ,
Clean Water Act ,
Climate Change ,
Environmental Liability ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Executive Orders ,
Groundwater ,
Hazardous Waste ,
NRDC ,
Presidential Memorandum ,
Trump Administration ,
Two For One Rule
The news has been full of stories and articles concerning Coal Combustion Residuals (CCR), also referred to as coal ash. CCR became a hot topic in 2008 when a coal ash pond at a utility plant in Tennessee spilled more than 5...more
5/20/2016
/ Air Pollution ,
Clean Air Act ,
Coal Ash ,
Consent Decrees ,
Deepwater Horizon ,
Department of Environmental Quality ,
Department of Justice (DOJ) ,
Department of Labor (DOL) ,
Environmental Crimes ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Groundwater ,
Hazardous Communication Standard ,
Hazardous Waste ,
Individual Accountability ,
OSHA ,
RCRA ,
Safety Data Sheets ,
Sierra Club ,
Solid Waste ,
SSM Periods ,
Superfund ,
Toxic Chemicals ,
Training Requirements ,
Utilities Sector ,
Workplace Safety ,
Yates Memorandum
EPA’s Office of Enforcement and Compliance Assurance recently proposed changes to its National Program Manager (NMP) Guidance that, in part, would revise EPA’s National Enforcement Initiatives (“NEIs”) for federal fiscal...more
EPA’s Office of Enforcement and Compliance Assurance recently proposed changes to its National Program Manager (NMP) Guidance that, in part, would revise EPA’s National Enforcement Initiatives (“NEIs”) for federal fiscal...more
4/27/2016
/ Air Pollution ,
Chemical Spills ,
Clean Water Act ,
Climate Change ,
Comment Period ,
Confidential Information ,
Critical Habitat ,
Endangered Species Act (ESA) ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
FOIA ,
Hazardous Waste ,
Obama Administration ,
OSHA ,
Penalties ,
Power Plants ,
Wastewater ,
Workplace Hazards
The U.S. Supreme Court has blocked implementation of President Obama’s signature plan to address climate change pending a decision by the D.C. Circuit Court of Appeals on the plan’s legality. The Clean Power Plan is being...more
2/18/2016
/ CERCLA ,
Clean Power Plan ,
Clean Water Act ,
Duke Energy ,
Environmental Protection Agency (EPA) ,
Hazardous Waste ,
Justice Scalia ,
Order to Stay ,
Permits ,
SCOTUS ,
Storm Water Pollution Prevention Plan ,
US Fish and Wildlife Service ,
Waste Management
In a significant setback for the Obama Administration, the U.S. Court of Appeals for the Sixth Circuit has temporarily blocked implementation of the Clean Water Rule issued jointly by EPA and the U.S. Army Corps of Engineers...more
10/28/2015
/ Barack Obama ,
CERCLA ,
Clean Air Act ,
Clean Water Rule ,
Customs and Border Protection ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Hazardous Waste ,
Importers ,
Imports ,
Proposed Amendments ,
RCRA ,
Toxic Substances Control Act (TSCA) ,
U.S. Customs ,
US Army Corps of Engineers ,
Waste Management ,
Waters of the United States
In this Issue:
- EPA Issues SIP Call to Eliminate SSM Defense
- EPA and Corps Define “Waters of The United States”
- Frequent Questions: EPCRA 313
- Generators Need to be Vigilant About TCLP Sampling...more
6/15/2015
/ CERCLA ,
Clean Air Act ,
Clean Water Act ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Waste ,
Manufacturers ,
NAAQS ,
Ozone ,
Proposed Regulation ,
RCRA ,
Reporting Requirements ,
Sierra Club ,
Toxic Chemicals ,
US Army Corps of Engineers ,
Waste Disposal